Best Practices in Child Support System Modernization

DEAR COLLEAGUE LETTER

ACF-OCSS-DCL-24-12

DATE: November 6, 2024

TO:  Governors, State Chief Information Officers, and IV-D (Child Support) Directors

SUBJECT:  Best Practices in Child Support System Modernization

Dear Colleague:

The Administration for Children and Families’ (ACF) Office of the Chief Technology Officer (OCTO) and Office of Child Support Services (OCSS) have collaborated to share the following guidance of best practices in state system modernization. This guidance seeks to minimize risk of modernization challenges, ensure compliance with federal requirements, and encourage technology that enables the child support community to effectively support responsible parenting, family self-sufficiency, and child well-being.

Technology is critical to support ACF goals of promoting parental responsibility and providing children with the support they need to thrive.  Effective technology has the immense potential to reduce administrative burden for custodial and noncustodial parents, improve oversight for child support programs, boost productivity of program staff, ensure federal compliance, and more. Modernizing state systems that underpin child support programs is a crucial step in achieving these goals.

Child support system modernization projects are complex, costly, and time-intensive, and it is vital that these efforts are successful, as failure can impact the receipt of vital support for families. For a project to be successful, the modernized system must be federally compliant and meet the needs of the business stakeholders and the needs of the system users, while balancing the constraints of cost, time, and scope.

ACF strongly recommends that states consider the following industry best practices during the modernization process.

Best Practice:  Involve the right people

Modernization efforts are improved when key stakeholders collaborate throughout the process, including the IV-D Director (or designee) as the executive sponsor, state Chief Information Officer (CIO) as a co-sponsor (as applicable), state technical staff, and end users. As executive sponsor, the IV-D Director is responsible for establishing the long-term vision of the modernized system and guiding the project’s progress. The IV-D Director serves in a leadership role during a modernization effort, as they have crucial subject-matter expertise on the child support program. As co-sponsors, state CIOs, and technical staff have IT expertise and can support the modernization strategy and guide progress. Furthermore, 45 CFR 95.626 emphasizes the importance of involving state program offices in the development and implementation of a modernization project.

We advise staffing a modernization project with government and contract staff who have the relevant technical, design, product, and project management skillsets, whether via assigning, upskilling, or hiring (as budget permits). States should also consider providing training to state project staff on managing modernization projects, such as the Agile project management approach. These state staff can work closely with Design Development and Implementation vendors to guide development, based on the state procurement rules and regulations.

Best Practice: Apply strategies for success

Modernization efforts can carry high amounts of risk. Below are recommended strategies that can improve odds of success.

Define requirements. Defining the modernized system’s goals and functional requirements at the start of a project may reduce change order requests, minimize unexpected cost increases, and avoid time delays for implementation. States should have conversations with OCSS, peer state personnel, and end users during this process.

Incorporate change management. We advise conducting change management efforts from the start and continuing after concluding the project to ensure successful system adoption. Systematically identifying, communicating, and mitigating potential risks associated with change helps states proactively address delays, minimize disruption, and maximize successful adoption of a modernized system.

Deliver value in steps.  Whenever possible, modernization efforts should focus on delivering value in small, manageable steps. As the new system is being built, real users should be able to test it early and new features should be delivered often. This method allows the team to learn and adapt throughout the project, making sure the system meets user needs.

Conclusion

Modernizing a child support system is a complex endeavor. With the right people, approach, and knowledge, system modernization can be done successfully and promote better outcomes for states, families, and children. ACF and OCSS will support you at every stage of the process. We invite you to reach out with questions or concerns to OCSS.DSTS@acf.hhs.gov.

Tanguler Gray
Commissioner
Office of Child Support Services

Kevin Duvall
Chief Technology Officer
Administration for Children and Families

Additional Resources

There are three types of Advance Planning Documents (APDs). See 45 CFR 95.610 for the specific requirements for each of these APDs:

• Planning APD (PAPD), which is highly recommended, is done at the start of a modernization project. The PAPD requirements include activities such as problem needs assessment, feasibility study, alternatives analysis, cost-benefit analysis, and functional requirements specification. These activities help to explore options for a state and identify the best approach in a complex modernization project. States can use the Planning APD template.
• Implementation APD (IAPD) is required at the end of the planning phase, before beginning procurement or development. The IAPD is used to request overall approval of a modernization project, specifically the Federal Financial Participation (FFP) in the cost of designing, developing, and implementing the system.
• Annual Advance Planning Document Update (AAPDU) is required 60 days prior to expiration of FFP approval.

We also suggest this Cost Allocation Methodologies Toolkit to help expedite the approval process for State Cost Allocation Plans submitted under an APD.

Feasibility studies (PDF) are also done at the start of a modernization project. Re-platforming, refactoring, or enhancing an existing system does not trigger a feasibility study requirement. A feasibility study is required when using a commercial-off-the-shelf or custom approach.

Because a system must be certified when development is complete, states must consult the current 2017 state system certification guide throughout the life cycle of the modernization, especially when developing requirements for a new system. System certification requirements are key for achieving a federally certified system and will guide the final review for federal certification.

Independent Verification and Validation (IV&V) may be required under certain conditions (45 CFR 95.626 ). The IV&V requirement depends on risk level, scope, or waiver usage.

Once a commercial-off-the-shelf system is certified as a Child Support Enforcement System, it is considered a government-off-the-shelf (GOTS) system and may be available for transfer to other states. States can request a waiver in the APD to maintain FFP, which would otherwise be prohibited under 45 CFR 95.627 . (See ACF OA-PI-13-01 (PDF) for instructions.)

For additional resources on procurement and development, we suggest the Modernization Checklist or U.S. Digital Service guidance or 45 CFR part 95, subpart F on the design of software development contracts.

For information on the HHS department-wide management policy to promote greater alignment of health IT activities consisting of requirements for implementing, acquiring, or upgrading health IT, see HHS Health IT Alignment Policy Resources .